• When is a CFC a resident of a section 404 country?

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    A CFC is resident of a section 404 country if:

    • the CFC is not a Part X Australian resident
    • the CFC is treated as a resident of a section 404 country under the tax laws of that country, and
    • the CFC is not treated as a resident of a listed country at that time for the purposes of the tax law of the listed country.
    Last modified: 05 Dec 2006QC 18000